News & Analysis as of

Rule of Two Department of Veterans Affairs

Pillsbury - Bid Protest Debrief

Risk Too High? GAO Says You Don’t Have to Bid

In Protection Strategies Etc. International, LLC, B-423539 (Aug. 25, 2025), Protection Strategies, a service-disabled veteran-owned small business (SDVOSB), filed a pre-award protest challenging the terms of a solicitation...more

Morrison & Foerster LLP - Federal Circuitry

Last Week in the Federal Circuit: Waiver and Constitutional Avoidance

The Federal Circuit issued just one precedential opinion last week.  But it’s an interesting one:  The Court exercised its discretion to reach (or rather, avoid) a constitutional issue not pressed or passed upon by the trial...more

Holland & Knight LLP

February 2020 Small Business Roundup

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Veteran-Owned Business Priority - In 2016, the U.S. Supreme Court surprised many by hearing a bid protest concerning the application of the "Rule of Two" for veteran-owned small businesses in procurements run by the U.S....more

Holland & Knight LLP

GAO Rules That Kingdomware "Rule of Two" Does Not Govern Leasehold Acquisitions Conducted by GSA on Behalf of VA

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The U.S. Government Accountability Office (GAO) ruled on Dec. 20, 2019, that the "Rule of Two" of the Veterans Benefits, Health Care, and Information Technology Act of 2006 (VBA) does not require the U.S. General Services...more

Sheppard Mullin Richter & Hampton LLP

Veterans Are First at the VA Following New Class Deviation Implementing Recent Federal Circuit Mandate

In its most recent attempt to strike the appropriate balance between the Veterans First and AbilityOne programs, the U.S. Department of Veterans Affairs (“VA”) issued on May 20, 2019 a class deviation to the VA Acquisition...more

Bradley Arant Boult Cummings LLP

The 3 Most Important Bid Protest Decisions Of 2018 - Law360

In 2018, three particularly important decisions were issued that will have a significant impact on bid protest law for years to come: Dell Federal Systems LP v. United States, PDS Consultants Inc. v. United States, and Oracle...more

Pillsbury Winthrop Shaw Pittman LLP

Kingdomware Revisited: VA’s “Rule of Two” Takes Priority Over AbilityOne

The U.S. Court of Appeals for the Federal Circuit finds the Department of Veterans Affairs’ (VA) Rule of Two takes priority over older and less specific statutory procurement mandates. The Federal Circuit found that the VA...more

Jones Day

Court Puts Vets First: "Rule of Two" Prevails Over AbilityOne

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The U.S. Court of Federal Claims ("COFC") recently ruled that the Department of Veterans Affairs ("VA") must apply the "Rule of Two" before consulting the AbilityOne list when buying goods and services....more

PilieroMazza PLLC

House Proposes Broader Application of “VA Rule of Two” to Close Kingdomware Loophole

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On June 6, 2017, a bipartisan pair of lawmakers introduced a bill in the U.S. House of Representatives, H.R. 2781, known as the Ensuring Veteran Enterprise Participation in Strategic Sourcing Act (“Bill”), which, if passed,...more

Smith Anderson

Supreme Court Requires Many More VOSB Set-Asides

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On June 16, 2016, the United States Supreme Court ruled that the Department of Veterans Affairs (VA) must apply the “Rule of Two” in all contracting decisions in Kingdomware Technologies, Inc. v. United States, 136 S.Ct. 1969...more

Bradley Arant Boult Cummings LLP

The “Rule of Two” Rules the Day in Supreme Court’s Decision Against the VA

The recently decided case of Kingdomware Technologies, Inc. v. United States marks a big win for small business-owning veterans. The Supreme Court unanimously decided that the Department of Veterans Affairs (VA)...more

Harris Beach Murtha PLLC

Construction Law Group News: Veteran-Owned Contractors: SCOTUS Reaffirms the “Rule of Two,” which is Good for You!

The U.S. Supreme Court’s ruling last week in Kingdomware Techs., Inc. v. U.S. should create more opportunities for veteran-owned and service-disabled veteran-owned small businesses (collectively, "VOSBs") to win contracts...more

Kilpatrick

Supreme Court Finds The Department of Veterans Affairs Violated Procurement Law – Are There Broader Implications for Government...

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On June 16, 2016 the Supreme Court of the United States (“SCOTUS”) issued its much anticipated decision in the Kingdomware Technologies, Inc. v. United States case (“Kingdomware”). One of two important cases, both decided on...more

Morgan Lewis

Supreme Court Requires the VA to Expand Use of Mandatory Set-Asides for VOSBs

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The Department of Veterans Affairs will be required to implement mandatory set-aside requirements for procurements at all levels, including FSS orders, if two or more VOSBs reasonably can be expected to submit offers that...more

Dorsey & Whitney LLP

The Supreme Court - June 2016 #4

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The Supreme Court of the United States issued decisions in three cases on June 16, 2016: Universal Health Services, Inc. v. United States ex rel. Escobar, No. 15-7: Yarushka Rivera, a teenage beneficiary of...more

PilieroMazza PLLC

Kingdomware Oral Arguments—Remand to Lower Courts Is a Possibility

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“Yeah, it’s a contract,” conceded Department of Justice (“DOJ”) attorney Zachary Tripp during recent oral arguments in Kingdomware Technologies Inc. v. United States. According to Tom Saunders, attorney for Kingdomware, that...more

PilieroMazza PLLC

Kingdomware Vs. the VA: Supreme Court Case to be Dismissed?

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If you are already aware of the Kingdomware case, you will likely be surprised to hear that on November 4, 2015, the U.S. Supreme Court issued an order to the parties in the Kingdomware case to submit briefs on whether the...more

Sheppard Mullin Richter & Hampton LLP

Supreme Court to Hear VA Procurement Controversy This Fall

In a matter of keen interest to the small business community, last month the Supreme Court, granted certiorari in Kingdomware Technologies, Inc. v. United States. The Court’s decision will hopefully bring some closure to the...more

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